Ireland’s planned e-invoicing reform has moved from consultation papers into draft law. The Finance (No. 2) Bill 2026, published by the Department of Finance on 19 October 2026, amends the VAT Consolidation Act to introduce two connected obligations: issuing invoices in a structured electronic format, and transmitting invoice data to the Revenue Commissioners (Ireland’s tax and customs authority) at the moment each invoice is issued.
The phased timeline Revenue had already signalled is now written into the text. What the bill adds is precision: exactly who falls into the first wave, how that group is fixed, what counts as a structured invoice, and which special transactions are covered. The technical detail, including the data fields to be reported and the transmission channel, is left to regulations still to come.
Key Dates
| Date | Milestone |
| 19 October 2026 | Finance (No. 2) Bill 2026 published |
| 1 January 2027 | Amendments take effect in the VAT Consolidation Act; first reference date for identifying in-scope large businesses |
| 1 January 2028 | Second reference date for identifying in-scope large businesses |
| 1 November 2028 | Phase one: large businesses must issue structured e-invoices and report invoice data |
| 1 November 2029 | Phase two: scope widens to businesses trading within the EU |
| 1 July 2030 | EU-wide ViDA requirements apply to intra-EU B2B transactions |
Two Obligations in One Reform
The bill does not stop at invoice format. It creates a new invoicing rule and, alongside it, a new chapter on digital reporting.
The invoicing rule requires in-scope businesses to issue domestic B2B invoices in a structured electronic format. The reporting rule requires those same businesses to send Revenue a defined set of data on each transaction, at the time the invoice is issued or should have been issued. In practice, the invoice and the report are produced from the same event, which is why Ireland’s reform is better described as a combined e-invoicing and real-time reporting regime than as an e-invoicing mandate with reporting added later.
Who Is in Scope, and When
Phase One: Large Businesses
From 1 November 2028 to 31 October 2029, the obligations apply to businesses established in Ireland whose tax affairs were managed by Revenue’s Large Corporates Division (the unit that administers the country’s largest taxpayers) on 1 January 2027.
The use of a fixed reference date matters. A business does not move in or out of the first wave depending on its status in 2028. Its position on 1 January 2027 decides it, which gives every company a clear answer more than eighteen months before the start date.
Phase Two: Wider Scope
From 1 November 2029, the obligations extend to businesses established in Ireland that:
- were managed by the Large Corporates Division on 1 January 2027, or
- were managed by the Large Corporates Division on 1 January 2028, or
- carry out intra-EU supplies or acquisitions of goods or services.
The second wave therefore captures both businesses that joined the Large Corporates Division during 2027 and, more significantly, every Irish business trading with suppliers or customers elsewhere in the EU.
Everyone Else
Businesses outside these groups may issue structured e-invoices and report data voluntarily. The bill also removes the need for the recipient’s consent: a structured e-invoice can be issued without the buyer’s prior agreement. As a result, every Irish business needs to be able to receive and process structured invoices from the first phase onwards, even if it is not yet required to issue them.
What Counts as a Structured E-Invoice
The bill defines a structured electronic format by reference to the European standard EN 16931 and the syntaxes recognised under the EU directive on public sector e-invoicing, which in practice means UBL and CII. PDFs and scanned images do not qualify.
The obligation covers supplies to other businesses established in Ireland and to public bodies, so B2G invoicing falls within the same rule. Several further requirements apply:
- Customer identification. Every structured invoice must carry the buyer’s identification number. For VAT-registered customers this is the VAT number. Where a customer or public body is not VAT-registered, Revenue will assign it a separate tax reference number for this purpose, and buyers must provide their number to suppliers on request.
- Summary invoices. Several supplies made to the same customer within a calendar month may be combined into a single monthly structured invoice.
- Credit and debit notes. Any document amending a structured invoice must be issued in the same structured format as the original.
- Business controls. Both the issuer and the recipient must apply controls that guarantee the authenticity of origin, the integrity of content and a reliable audit trail linking the invoice to the underlying supply. Revenue may ask for evidence of these controls.
Self-Billing and Domestic Reverse Charge
Self-Billing
Where the customer issues invoices on the supplier’s behalf, the obligations shift to the customer. If the customer is an in-scope business and both parties are established in Ireland, the customer must issue the self-billed invoice in structured form and report the data no later than five days after issuance. Out-of-scope customers may follow the same approach voluntarily.
Reverse Charge Supplies
For domestic supplies where the buyer accounts for VAT, in-scope suppliers must issue a structured document stating that the recipient is liable for the tax, with the same particulars as an invoice but without the VAT rate or amount. The bill lists the transactions concerned:
- Greenhouse gas emission allowances
- Services provided by subcontractors under the construction sector reverse charge
- Scrap metal
- Construction work
- Gas and electricity
- Gas and electricity certificates
Except for emission allowances, the parties may agree to apply self-billing to these documents.
How Reporting Works
The reporting chapter applies from 1 November 2028 to domestic supplies. An in-scope supplier must transmit the prescribed data on each individual transaction at the time the invoice is issued. The data set itself, and the form and manner of transmission, will be specified by regulations.
Two features stand out. First, the obligation sits with the issuer. Apart from self-billing, the bill does not require buyers to report their purchases separately, which distinguishes Ireland from jurisdictions that have opted for reporting by both parties. Second, the bill allows a third party to transmit the data on the business’s behalf, which opens the role to e-invoicing service providers and accounting software.
What the Bill Leaves to Regulations
The bill establishes the legal framework but leaves the operational architecture open. Three points remain to be settled:
- The data set. The specific fields to be reported have not yet been defined.
- The transmission channel. The bill does not name Peppol or any other network. Revenue has been working with the Irish Peppol Authority, and an exchange model in which service providers both deliver invoices and report to Revenue is widely expected, but this is not yet a legal requirement.
- The intra-EU layer. The reporting provisions published so far cover domestic supplies. The EU-wide requirements for intra-EU transactions from 1 July 2030 will need their own implementing rules.
Preparing for November 2028
With the scope fixed by reference date, most large businesses can already confirm whether they fall into the first wave. For those that do, the work extends well beyond accounts receivable. Invoice data has to be generated correctly, exchanged in a structured format, reported to Revenue at issuance and remain consistent with accounting records and VAT returns. Because Revenue will see transaction data as invoices are issued, any gap between the e-invoice, the ERP record and the later VAT return becomes visible far earlier than under periodic filing.
Businesses outside the first wave should not treat the two-year window as a reason to wait. From November 2028 they must be able to receive structured invoices from their larger suppliers, and from November 2029 every company trading within the EU is in scope.
RTC, as an Irish-registered and certified Peppol Access Point, supports businesses in building the structured invoicing and reporting capability the new regime requires
